Excise duty exemption for paper board cannot be extended retrospectively beyond the notification's plain wording.

Excise duty exemption for paper board was confined to the scope of the notifications as written and could not be extended retrospectively to clearances from 1979. The 9 November 1984 amendment was read as referring back only to the 24 April 1981 notification, and its language could not be used to carry the exemption into the 2 April 1984 notification. The Court held that policy purpose cannot enlarge an exemption beyond the text where the wording is clear, and it also found the different cut-off date for paper board to be rational rather than discriminatory. The claimed extended benefit was therefore denied.

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Issues: Whether the exemption from excise duty in respect of paper board could be extended retrospectively to clearances from 1979 on the basis of the notifications issued in 1981, 1984 and the amendment of 9 November 1984.

Analysis: The governing notifications were construed on their plain language. The 9 November 1984 notification substituted the second proviso in the 24 April 1981 notification and, by its wording, referred back to that notification. The expression used in the amended proviso could not be read as carrying the exemption into the 2 April 1984 notification so as to confer benefit from 1979. The Court rejected the attempt to enlarge the scope of the exemption by invoking the object of the policy, holding that while purpose may assist where literal interpretation creates ambiguity or absurdity, it cannot be used to extend the subject of exemption beyond what the notifications actually provided. The differential treatment of paper board from 2 April 1984 was held to be rational and not discriminatory, since the Government was entitled to fix a different cut-off date for a different product category.

Conclusion: The exemption could not be claimed from 1979, and the challenge to the denial of such extended benefit failed.

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